On October 10, 2013 a
Party Statement
was filed
involving a dispute between
Dodd, David,
Dodd, Michelle,
and
Betteravia Farms Llc,
Bonita Packing Co,
for Unlimited Other PI/PD/WD (23)
in the District Court of Santa Barbara County.
Preview
DE
—— - _
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name. 3q 0e! new;
number. and iron COURT uaa ONLY
CM-IIIF
KEVIN CHOLAKIAN (103423) / BRIAN FINN (14238) DX__.
CI-IOLAKIAN & ASSOCIATES
400 OYSTER POINT BLVD. so. SAN FRANCISCO. CA 94o
TELEPHONE NC; 650-871-9544
W“V‘°°'“‘i°'"°"i°i
FAX No (ammo:
SUPERI f R
I
co
L RT ofCALIFORNIA N
DEFENDANTS. BONITA PACKING CO. BETTERAVIA COUNTY ANTA BARBARA
. _
ATTORNEY son mam): oi
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA BAREARA
sTRaETAOORass:312-0 E. COOK STREET SEP 2 2 2014
AooREss‘: Derrel E. Parker. Executive Officer
MNLINC
SANTA MARIA 93454 TT
_
cnwerywyfcoom By
“M” W”:
,
SANTA MARIA CIVIL DIVISION .
.
nun _v. on en
..
PLAINTIFF/PETITIONER: DAVID 0000 and MICHELLE 0000 _r
°
DEFENDANT/RESPONDENT: BONITA PACKING. et el.
CASE MANAGEMENT STATEMENT CW3 NW3“
(Check one): [23 UNLIMITED CASE [:3 LIMITED CASE 1457671
p
(Amount dgmanded (Amount demanded 525.000
h
Ie
"’ i,
exceedes
AX
5.000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows: I 1"
Date: 10/06/14 Time: 8530 AM. Dept: 8M2 Div.: Room:
Address of court
m
from the address above):
(if different
Notice of intent to Appear by Telephone,by (name): BRIAN J. FINN
iNSTRUCTIONs: All applicable boxee muet be checked. and the epocitled Informationmuet be provided.
m
Petty or pertiee (answer one):
(BTU
1. .LHflOO
DEFENDANTS. BONITA PACKING 00.. BETTERAVIA FARMS
_
HQIIC‘HRV
e. This etetement ie submitted by petty (name):
MW
b. I:I This etate'r‘nent‘le submitted jointly by parties (names);
lNVIISHnd
SIHL
E
OHSIHBU
‘Compieint and croee-complelnt (to be answered by plaintiffs and cross-complainants only)
L
‘2.
01
Ecomplalnt was filed On (dole):
873.i
2: The cross-complaint.if any. wae'flled on (dete):
9!
3108
I311
3. Service (tobe answered by plaintiffs end cross-complainants
only) US'3
:I
SIHLBEIGISNOG
a. named
All parties Inthe complaint and oroee~complalnt have been served. have appeared. or heve been dismissed.
:1
.i
b. The followingpartleanamed Inthe complaint or croee-oomplelnt 'O‘H'O
CI
S‘I’H
(1) have not been served (specify names and explain why not):
3'8
CI
'HBdVd
3H1
I'l
_(2) have been served but have not appeared and have not been dismissed (specify names):
:I
E
(3) have’h‘ad a default entered against them (specify names):
‘c. The following addltlonel
partiesmay be added (specifynames. nature of involvement
incase, and date by which
they may be served).-
4. Description ofoeae
8- TYPO Ofimeln E complaint :1 cross-Complaint (Describe, including causes or action):
Page
1cl e
"mgmmwgmflg" CASE MANAGEMENT STATEMENT
_
CM-Ho IR".
Ju1y1.2011|
cmwaggfi
vw.ccum.ce.gOv
CM-110
PLAINTIFF/PETITIONER: DAVID 0000 and MICHELLE DODD “Sly-I’m
1‘ 6
oerENeANT/RESPONDENT: BONITA PACKING. et ai. 1
~
~ ~
4. b. Provide a brief statement of the case. Including any damages. (personal Injury damages are sought, spe'clly the Injury and
damages claimed, Including medical expenses to data (indicate source and amount), estimated future medical expenses, lost
eamlngs to date. and estimated rurm lost earnings. ll equitable relief is sought, describe the nature of the relief.)
Plaintiff alleges he was Injured while making a delivery to defendants' plant. He claims traumatic brain injury and
emotional distress damages. Defendants deny liability and dispute Plaintiff's damage claims.
D more space is needed, check this box and attach a page designated as Attachment 4b.)
E
(If
5. Jury or noniury trial
The party or parties request[Z] a My trial a nonjurytrial. name of each party
(ifmare than one party, provide the
requesting a jury trial):
9’
Trialdate
a. i: The has been set for (data):
trial
b. [I] No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (ll
not, explain):
Plaintiff's damages claims are extensive and will require multiple physical and mental examinations.
c. Dates on which parties or attoma'ys will not be available for trial (specify dates and explain reasons for unavailability):
Please see attached form MC-‘025
7. Estimated length of trial
The party or parties estimate
that the take (check one):
trial will
a. CD days(specify number):12 ' 15“W
b. [2 hours(short causes) (specify):
a.
a. Attorney:
be answered for each party)
Trial representation (to
The party or parties will be represented at trial
[I] by the ettomey or party listed
Inthe caption D by the following:
b. Firm:
c. Address:
d. Telephone number: r_ Fax number.
0. addresfl: Pu-W rgpnsonted;
[:1 Additional representation
isdescribedinAttachment B.
9. Preference
:1 This caseis code section):
entitled to preference (specify
10. Alternativedispute resolution (ADR)
a. ADR information package. Please note that different ADR processes are available In different courts and communities: read
the ADR information package provided by the court under rule 3.221
D
for information about the processes available through the
courtand community programs In this case.
(1) [I]
For parties represented by counsel: Counsel has has not provided theADR information package identified
D
In rule 3.221 to the client and reviewed ADR options with the
client.
(2) [3
For self-represented parties: Party has has not reviewed the ADR iniormation package identified In rule 3.221.
b. Referral to Judicial arbitration or civil action mediation (lfavailabie).
(1) :1 This matter Is sub act to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action
D
ode of Civil Procedure section 1775.3 because the amount In controversy does not exceed the
mtgtditationuunger
s u ory m g
Plaintiff elects to refer this case to Judicial arbitration
and agrees reccvery to the amount specified
(2) to limit InCode of
Civil Procedure section 1141.11.
(3) I: This case is exam
mediation under
tfrom judicial arbitration under rule 3.811 of the California Rules of Courtor from
ode of Civil Procedure section 1776 et seq. (specify exemption): '
action
civil
CM-"NR" M 1 2°"!
CASE MANAGEMENT STATEMENT "um"
Olin-11o
_ PLAINTlFF/PETITIONER: DAVID noon and MICHELLE oooo WNW-am
DEFENDANT/RESPONDENT; 1467671
~
a'o‘NiTA pACKING' ,, ,L
~
'16.c. ADR
Indicate the process orpr'oceeaea' have agreed
that the party or partiee are willing to participate
in. to participate or
in,
have already participated in (check all that apply and provide the specified Informal/on):
The party or parties completingif the party or partiea completing this form in the case have agreed to
are willing to
thle‘fo'rm participate in or have already completed en'ADR process or processes.
participate in the following ADR
indicate the statue of the processes (attach a copy' of the partlea'.ADR
prooeaeea (check all that apply):
af/pulatlon): _
m
Mediation seaaion not yet scheduled
-
Mediation eeaelon scheduledfor (date):
(1)M 0 C“ I u on
V
DUDE] .
Agreed tocomplete mediation by (date):
Mediation completed on (date):
Settlement conference not yet scheduled
(g)
-
nun'em
mmmm‘ Ea DDDEI Settlement conference scheduled for (date):
Agreed tocomplete settlement conference by
(date):
Settlement conference completed on (date):
E
Neutral evaluation not yet scheduled
Neutral evaluation scheduled for (date):
N eu raeve us u on
_
(3) t I l [IDEII]
‘ " '
Agreed tocomplete neutral evaluation by (date):
Neutral evaluation completed on (date):
scheduled
Judicial arbitration not yet
(4) Nonbmdlng Judlcm
'mmuon
I: HEIDI]
Judicial arbitration scheduled for (date):
Agreed tocomplete Judicial arbitration by (date):
completed on
Judicial arbitration (date):
D
Private arbitration not yet scheduled
Bindingprime Private arbitration scheduled for (date):
mmum
(5) DUDE]
Agreed tocomplete private by
arbitration (data):
on
Private arbitration completed(date):
ADR eeeeion not yet scheduled
(a)0th If ( spec1M
I
I
:1 HEIDI]
Ana aeeelon scheduled for (date):
ADR aeeelon by (date):
'
Agreed tocomplete
ADR completed on (date):
Cid-110 (lav; any
2011]
CASE MANAGEMENT STATEMENT
1.
Page a of!
c ;
_
PLAINTIFF/PETITIONER: DAVID Dow and MICHELLE DODD WNW"?
145767
~
DEFENDANT/RESPONDENT: BONITA PACKING. et al.
~
‘11.inauranoe
s. Insurance center.
Ifan'.for party statement (name):
filing this NATIONWIDE INSURANCE COMPANY
b. Reservation of rights: Yes [I] No
c. [2 Coverage issues significantly affect resolution of this case (explain):
Wiii
12, dariedictlon
indicateany matters that may affectttta court's Jurisdiction or processing of this case and describe the status.
[3 Bankruptcy [3 Other (spec/M:
Status:
,
13.
'
a, Q
Related cases. consolidation. and coordination
There are companion. underlying. or related cases.
(1)Name or case:
Name of court.
'
(2)
E
(3)Case nurn'ben
(4) Status:
Additional cases are described in Attachment 13s.
b. i: Amotion to :1 consolidate [:1 coordinate wiilbeflied by (name party):
Btfurcation
'14.,
The partyor parties lntend to file a motion for an order bifurc'ating. severing. or coordinating the following Issues or
causes of
action (specify moving party, type of motion, and reasons):
15.Other motions
:1 The party or parties expect tothe following motions before
file (specify moving party, type ofmotion,
trial and Issues),-
16. Discovery
a. [:1 The party or parties have completed all discovery.
b. E] The be completed by the date specified (describe
following discovery will allanticipated discovery):
Bart! Description Data
DEFENDANTS DEPOSITIDNS OF WITNESSES 04/2015
DEFENDANTS INDEPENDENT MEDICAL EXAMS 06/2015
DEFENDANTS EXPERT DISCOVERY Per Code
c, E The 'm
following discovery issues. including issues regarding the discovery of electronically stored Information.
anticipated (specify);
investigation and discovery is continuing as to plaintiff's damage claims. it is certain that defendant
may
require more than one independent medical examination and/or a mental examination of plaintiff.
OM-110[Rev.Jtdy1.20tf]
CASE MANAGEMENT STATEMENT Page a of"!
— PLAINTlFF/PETlTiONER: DAVID DODD and MICHELLE 0000 ‘3‘“"Wm
1467671
DEFENDANT/RESPONDENT: BONITA PACK'NGu 913'-
~
~
17;
a..m
Economic litigation
This isa limited case
civil the
(i.e.; amount demanded
of Civil Procedure sections 90-98
willapply
Is
case.
to this
525.000 or less) and the economic procedures
litigation inCode
b. [:3 This Is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional
discovery will be filed (I! checked. explain specifically why economic Ill/gallon procedures neleflng to discovery or trial
should not apply to lhls case):
18. Other issues
I: The party or be considered or determined
parties request that the following additional matters at thecase management
conference
'
(sp'eolly):
19. Meet and confer
a.E] of Court
The party or parties have met and conferred with all
explain):
'
parties on subjects required by rule 3.724 of the Cellfomia Rules
all
(I! not,
b. After meetingand conferring as required
by rule 3.724 of the agree on the following
California Rules of Court, the parties
(rapidly):
number of pages attached
20. Total any):
(If 1
iam completely familiar with this case and will be fully prepared to'dlscuas the status of discovery and eltematlve dispute resolution.
as well as other issues raised by this statement. and will possess the authority to enter into stipulations on these issues at the time of
the case management conference. including the written authority of the party where required.
Date: September 19. 2014
BRIAN FlNN. aso.
OR PRINT NAME)
(TYPE ARTY OR ATTORNEY)
D
(TYPE 05! PRINT NAM!)
E (UGNATURE 0F PARTY OR ATTOINSY)
Additional signatures are attached.
CM‘HNRW'MH-NW CASE MANAGEMENT STATEMENT mm"
Me-oze
_SHORT TITLE:
Dpdd v. Bonita Peaking et al. Santa Barbara Superior Ceurt
CASE NUMBER:
1457671
~ ~ ~
ATTACHMENT (Number): 6c
may be used with any Judicial Council form.)
(This Attachment
6c. Dales on which parties or attorneys will not be available for trial (specify dates and explain reasons for
unavailability):
Unavailable 'dates due to scheduled 2015-2016:
trials in
1/5/15 (-2 Weeks)
1/6/15 (4 weeks)
1/12/1 5 (2 weeks)
1/12/15 (2 weeks)
1/20/15 (2 weeks)
1/26/15 (2 weeks)
2/2/15 (2 weeks)
2/9/15 (2 weeks)
2/9/15 (2 weeks)
12/23/15 (-2weeks)
2123/1 5- (2 weeks)
3/2/15 (2' weeks)
3/2/15 (2 weeks)
3/2/15 (2 weeks)
3/16/15 (2 weeks)
3/30/15 (3 weeks)
4/1/15 (2 weeks)
4/3/15 (2 weeks)
'4/6/15 (2 weeks)
4/20/15 (2 weeks)
4/27/ 15 (2 weeks)
5/4/15 (2 weeks)
5/11/15 (2 Weeks;
5/11/151(2 weeks
5/22/15 (2 weeks)
5/29/15 (2 weeks)
6/1/15 (2 weeks)
6/8/15‘(2 weeks)
6/15/15 (2 weeks)
(6/22/15 (2 weeks)
7/6/15 (2 weeks)
7/20/15 (2 weeks)
8/24/15 (2 weeks)
3/21/16 (2' weeks)
Attachment are
Efrem
rarm'
Attachment concams Is made under penalty ofper/ury,
(/ftno Item that this
made under penalty 0/ perjury.)
tor Ogle/Isl .0"
teams] at ATTACHMENT
allstatementsIn this "gem of~ 1
(Add pagans required)
immh/beamv
Jun unomra
M6025 raw. Jgty 1.20091 to Judlelal Counell Form
H
~
W At the time of service, I was over 18
~
years of age
Santa
and not
Barbara
a party
Superior Court
Case. Noti4‘57'67i
to the action. My
business address is 400 Oyster Point Blvd. Suite 415. South San Francisco. California 94080.
ensuesuau‘u
On September 22. 2014, I'se'rved the following document(a):
DEFENDANTS BONITA PACKING COMPANY AND BETTERAVIA FARMS LLC’S
CASE MANAGEMENT CONFERENCE STATEMENT
1 served the documents on the following persons at the following address (including fax
numbers and e-mail addresses. if applicable):
H Russell R. Ghitterman . Esq. Attorneys for Plainrwfr David Dodd and
Crystal C. Forsher,_ Esq. Michelle Dodd
GHI'I'TERMAN, GHITTERMAN 8t. EELD
_
H
418 E. CanOn Perdido Street
H
Santa Barbara. CA 93101
Tel: 805-965-4540
~
02-:
Fax: 805-965-5009
on.
The documents were served by the following means:
.—a
FE
L-
(EV MAIL) l sealed the envelope(s). with postage thereon fully prepaid, and on the
—-
date below. Iam readily familiar with the firm's practice for collection and processing
correspondence for mailing. Under that practice, ch ch same day that correspondenceis
placed for collection and mailing, it is deposited in the ordinary course of business with
a—n
a... the U.S. Egtal Service.
(BY OVERNIGHT
~
DELIVERY) By placing such sealed envelope. delivery fees paid.
in a facility regularly maintained by an overnight delivery service for receipt of such
'
-N'
M
documents. (CCP §1013)
[:1 (BY FACSIMILE) By transmitting to a facsimile machine maintained by the recipient
N'
at the facsim..le machine telephone number as lastjiven by that person.
new”
(STATE) I declare under penalty of perjury under the laws ofthe
~
State of California
N that the above is true and correct.
N
Executed on Septrnber 2-2,2014, at South San Francisco. Caiii’omia.
N
N
Lukomski
'
Natalia
N
m
259 064 PROOF OF SERVICE
Document Filed Date
September 22, 2014
Case Filing Date
October 10, 2013
Category
Unlimited Other PI/PD/WD (23)
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
DE —— - _ ATTORNEY OR PARTY WITHOUT ATTORNEY (Name. 3q 0e! new; number. and iron COURT uaa ONLY CM-IIIF KEVIN CHOLAKIAN (103423) / BRIAN FINN (14238) DX__. CI-IOLAKIAN & ASSOCIATES 400 OYSTER POINT BLVD. so. SAN FRANCISCO. CA 94o TELEPHONE NC; 650-871-9544 W“V‘°°'“‘i°'"°"i°i FAX No (ammo: SUPERI f R I co L RT ofCALIFORNIA N DEFENDANTS. BONITA PACKING CO. BETTERAVIA COUNTY ANTA BARBARA . _ ATTORNEY son mam): oi SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA BAREARA sTRaETAOORass:312-0 E. COOK STREET SEP 2 2 2014 AooREss‘: Derrel E. Parker. Executive Officer MNLINC SANTA MARIA 93454 TT _ cnwerywyfcoom By “M” W”: , SANTA MARIA CIVIL DIVISION . . nun _v. on en .. PLAINTIFF/PETITIONER: DAVID 0000 and MICHELLE 0000 _r ° DEFENDANT/RESPONDENT: BONITA PACKING. et el. CASE MANAGEMENT STATEMENT CW3 NW3“ (Check one): [23 UNLIMITED CASE [:3 LIMITED CASE 1457671 p (Amount dgmanded (Amount demanded 525.000 h Ie "’ i, exceedes AX 5.000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: I 1" Date: 10/06/14 Time: 8530 AM. Dept: 8M2 Div.: Room: Address of court m from the address above): (if different Notice of intent to Appear by Telephone,by (name): BRIAN J. FINN iNSTRUCTIONs: All applicable boxee muet be checked. and the epocitled Informationmuet be provided. m Petty or pertiee (answer one): (BTU 1. .LHflOO DEFENDANTS. BONITA PACKING 00.. BETTERAVIA FARMS _ HQIIC‘HRV e. This etetement ie submitted by petty (name): MW b. I:I This etate'r‘nent‘le submitted jointly by parties (names); lNVIISHnd SIHL E OHSIHBU ‘Compieint and croee-complelnt (to be answered by plaintiffs and cross-complainants only) L ‘2. 01 Ecomplalnt was filed On (dole): 873.i 2: The cross-complaint.if any. wae'flled on (dete): 9! 3108 I311 3. Service (tobe answered by plaintiffs end cross-complainants only) US'3 :I SIHLBEIGISNOG a. named All parties Inthe complaint and oroee~complalnt have been served. have appeared. or heve been dismissed. :1 .i b. The followingpartleanamed Inthe complaint or croee-oomplelnt 'O‘H'O CI S‘I’H (1) have not been served (specify names and explain why not): 3'8 CI 'HBdVd 3H1 I'l _(2) have been served but have not appeared and have not been dismissed (specify names): :I E (3) have’h‘ad a default entered against them (specify names): ‘c. The following addltlonel partiesmay be added (specifynames. nature of involvement incase, and date by which they may be served).- 4. Description ofoeae 8- TYPO Ofimeln E complaint :1 cross-Complaint (Describe, including causes or action): Page 1cl e "mgmmwgmflg" CASE MANAGEMENT STATEMENT _ CM-Ho IR". Ju1y1.2011| cmwaggfi vw.ccum.ce.gOv CM-110 PLAINTIFF/PETITIONER: DAVID 0000 and MICHELLE DODD “Sly-I’m 1‘ 6 oerENeANT/RESPONDENT: BONITA PACKING. et ai. 1 ~ ~ ~ 4. b. Provide a brief statement of the case. Including any damages. (personal Injury damages are sought, spe'clly the Injury and damages claimed, Including medical expenses to data (indicate source and amount), estimated future medical expenses, lost eamlngs to date. and estimated rurm lost earnings. ll equitable relief is sought, describe the nature of the relief.) Plaintiff alleges he was Injured while making a delivery to defendants' plant. He claims traumatic brain injury and emotional distress damages. Defendants deny liability and dispute Plaintiff's damage claims. D more space is needed, check this box and attach a page designated as Attachment 4b.) E (If 5. Jury or noniury trial The party or parties request[Z] a My trial a nonjurytrial. name of each party (ifmare than one party, provide the requesting a jury trial): 9’ Trialdate a. i: The has been set for (data): trial b. [I] No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (ll not, explain): Plaintiff's damages claims are extensive and will require multiple physical and mental examinations. c. Dates on which parties or attoma'ys will not be available for trial (specify dates and explain reasons for unavailability): Please see attached form MC-‘025 7. Estimated length of trial The party or parties estimate that the take (check one): trial will a. CD days(specify number):12 ' 15“W b. [2 hours(short causes) (specify): a. a. Attorney: be answered for each party) Trial representation (to The party or parties will be represented at trial [I] by the ettomey or party listed Inthe caption D by the following: b. Firm: c. Address: d. Telephone number: r_ Fax number. 0. addresfl: Pu-W rgpnsonted; [:1 Additional representation isdescribedinAttachment B. 9. Preference :1 This caseis code section): entitled to preference (specify 10. Alternativedispute resolution (ADR) a. ADR information package. Please note that different ADR processes are available In different courts and communities: read the ADR information package provided by the court under rule 3.221 D for information about the processes available through the courtand community programs In this case. (1) [I] For parties represented by counsel: Counsel has has not provided theADR information package identified D In rule 3.221 to the client and reviewed ADR options with the client. (2) [3 For self-represented parties: Party has has not reviewed the ADR iniormation package identified In rule 3.221. b. Referral to Judicial arbitration or civil action mediation (lfavailabie). (1) :1 This matter Is sub act to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action D ode of Civil Procedure section 1775.3 because the amount In controversy does not exceed the mtgtditationuunger s u ory m g Plaintiff elects to refer this case to Judicial arbitration and agrees reccvery to the amount specified (2) to limit InCode of Civil Procedure section 1141.11. (3) I: This case is exam mediation under tfrom judicial arbitration under rule 3.811 of the California Rules of Courtor from ode of Civil Procedure section 1776 et seq. (specify exemption): ' action civil CM-"NR" M 1 2°"! CASE MANAGEMENT STATEMENT "um" Olin-11o _ PLAINTlFF/PETITIONER: DAVID noon and MICHELLE oooo WNW-am DEFENDANT/RESPONDENT; 1467671 ~ a'o‘NiTA pACKING' ,, ,L ~ '16.c. ADR Indicate the process orpr'oceeaea' have agreed that the party or partiee are willing to participate in. to participate or in, have already participated in (check all that apply and provide the specified Informal/on): The party or parties completingif the party or partiea completing this form in the case have agreed to are willing to thle‘fo'rm participate in or have already completed en'ADR process or processes. participate in the following ADR indicate the statue of the processes (attach a copy' of the partlea'.ADR prooeaeea (check all that apply): af/pulatlon): _ m Mediation seaaion not yet scheduled - Mediation eeaelon scheduledfor (date): (1)M 0 C“ I u on V DUDE] . Agreed tocomplete mediation by (date): Mediation completed on (date): Settlement conference not yet scheduled (g) - nun'em mmmm‘ Ea DDDEI Settlement conference scheduled for (date): Agreed tocomplete settlement conference by (date): Settlement conference completed on (date): E Neutral evaluation not yet scheduled Neutral evaluation scheduled for (date): N eu raeve us u on _ (3) t I l [IDEII] ‘ " ' Agreed tocomplete neutral evaluation by (date): Neutral evaluation completed on (date): scheduled Judicial arbitration not yet (4) Nonbmdlng Judlcm 'mmuon I: HEIDI] Judicial arbitration scheduled for (date): Agreed tocomplete Judicial arbitration by (date): completed on Judicial arbitration (date): D Private arbitration not yet scheduled Bindingprime Private arbitration scheduled for (date): mmum (5) DUDE] Agreed tocomplete private by arbitration (data): on Private arbitration completed(date): ADR eeeeion not yet scheduled (a)0th If ( spec1M I I :1 HEIDI] Ana aeeelon scheduled for (date): ADR aeeelon by (date): ' Agreed tocomplete ADR completed on (date): Cid-110 (lav; any 2011] CASE MANAGEMENT STATEMENT 1. Page a of! c ; _ PLAINTIFF/PETITIONER: DAVID Dow and MICHELLE DODD WNW"? 145767 ~ DEFENDANT/RESPONDENT: BONITA PACKING. et al. ~ ‘11.inauranoe s. Insurance center. Ifan'.for party statement (name): filing this NATIONWIDE INSURANCE COMPANY b. Reservation of rights: Yes [I] No c. [2 Coverage issues significantly affect resolution of this case (explain): Wiii 12, dariedictlon indicateany matters that may affectttta court's Jurisdiction or processing of this case and describe the status. [3 Bankruptcy [3 Other (spec/M: Status: , 13. ' a, Q Related cases. consolidation. and coordination There are companion. underlying. or related cases. (1)Name or case: Name of court. ' (2) E (3)Case nurn'ben (4) Status: Additional cases are described in Attachment 13s. b. i: Amotion to :1 consolidate [:1 coordinate wiilbeflied by (name party): Btfurcation '14., The partyor parties lntend to file a motion for an order bifurc'ating. severing. or coordinating the following Issues or causes of action (specify moving party, type of motion, and reasons): 15.Other motions :1 The party or parties expect tothe following motions before file (specify moving party, type ofmotion, trial and Issues),- 16. Discovery a. [:1 The party or parties have completed all discovery. b. E] The be completed by the date specified (describe following discovery will allanticipated discovery): Bart! Description Data DEFENDANTS DEPOSITIDNS OF WITNESSES 04/2015 DEFENDANTS INDEPENDENT MEDICAL EXAMS 06/2015 DEFENDANTS EXPERT DISCOVERY Per Code c, E The 'm following discovery issues. including issues regarding the discovery of electronically stored Information. anticipated (specify); investigation and discovery is continuing as to plaintiff's damage claims. it is certain that defendant may require more than one independent medical examination and/or a mental examination of plaintiff. OM-110[Rev.Jtdy1.20tf] CASE MANAGEMENT STATEMENT Page a of"! — PLAINTlFF/PETlTiONER: DAVID DODD and MICHELLE 0000 ‘3‘“"Wm 1467671 DEFENDANT/RESPONDENT: BONITA PACK'NGu 913'- ~ ~ 17; a..m Economic litigation This isa limited case civil the (i.e.; amount demanded of Civil Procedure sections 90-98 willapply Is case. to this 525.000 or less) and the economic procedures litigation inCode b. [:3 This Is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional discovery will be filed (I! checked. explain specifically why economic Ill/gallon procedures neleflng to discovery or trial should not apply to lhls case): 18. Other issues I: The party or be considered or determined parties request that the following additional matters at thecase management conference ' (sp'eolly): 19. Meet and confer a.E] of Court The party or parties have met and conferred with all explain): ' parties on subjects required by rule 3.724 of the Cellfomia Rules all (I! not, b. After meetingand conferring as required by rule 3.724 of the agree on the following California Rules of Court, the parties (rapidly): number of pages attached 20. Total any): (If 1 iam completely familiar with this case and will be fully prepared to'dlscuas the status of discovery and eltematlve dispute resolution. as well as other issues raised by this statement. and will possess the authority to enter into stipulations on these issues at the time of the case management conference. including the written authority of the party where required. Date: September 19. 2014 BRIAN FlNN. aso. OR PRINT NAME) (TYPE ARTY OR ATTORNEY) D (TYPE 05! PRINT NAM!) E (UGNATURE 0F PARTY OR ATTOINSY) Additional signatures are attached. CM‘HNRW'MH-NW CASE MANAGEMENT STATEMENT mm" Me-oze _SHORT TITLE: Dpdd v. Bonita Peaking et al. Santa Barbara Superior Ceurt CASE NUMBER: 1457671 ~ ~ ~ ATTACHMENT (Number): 6c may be used with any Judicial Council form.) (This Attachment 6c. Dales on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): Unavailable 'dates due to scheduled 2015-2016: trials in 1/5/15 (-2 Weeks) 1/6/15 (4 weeks) 1/12/1 5 (2 weeks) 1/12/15 (2 weeks) 1/20/15 (2 weeks) 1/26/15 (2 weeks) 2/2/15 (2 weeks) 2/9/15 (2 weeks) 2/9/15 (2 weeks) 12/23/15 (-2weeks) 2123/1 5- (2 weeks) 3/2/15 (2' weeks) 3/2/15 (2 weeks) 3/2/15 (2 weeks) 3/16/15 (2 weeks) 3/30/15 (3 weeks) 4/1/15 (2 weeks) 4/3/15 (2 weeks) '4/6/15 (2 weeks) 4/20/15 (2 weeks) 4/27/ 15 (2 weeks) 5/4/15 (2 weeks) 5/11/15 (2 Weeks; 5/11/151(2 weeks 5/22/15 (2 weeks) 5/29/15 (2 weeks) 6/1/15 (2 weeks) 6/8/15‘(2 weeks) 6/15/15 (2 weeks) (6/22/15 (2 weeks) 7/6/15 (2 weeks) 7/20/15 (2 weeks) 8/24/15 (2 weeks) 3/21/16 (2' weeks) Attachment are Efrem rarm' Attachment concams Is made under penalty ofper/ury, (/ftno Item that this made under penalty 0/ perjury.) tor Ogle/Isl .0" teams] at ATTACHMENT allstatementsIn this "gem of~ 1 (Add pagans required) immh/beamv Jun unomra M6025 raw. Jgty 1.20091 to Judlelal Counell Form H ~ W At the time of service, I was over 18 ~ years of age Santa and not Barbara a party Superior Court Case. Noti4‘57'67i to the action. My business address is 400 Oyster Point Blvd. Suite 415. South San Francisco. California 94080. ensuesuau‘u On September 22. 2014, I'se'rved the following document(a): DEFENDANTS BONITA PACKING COMPANY AND BETTERAVIA FARMS LLC’S CASE MANAGEMENT CONFERENCE STATEMENT 1 served the documents on the following persons at the following address (including fax numbers and e-mail addresses. if applicable): H Russell R. Ghitterman . Esq. Attorneys for Plainrwfr David Dodd and Crystal C. Forsher,_ Esq. Michelle Dodd GHI'I'TERMAN, GHITTERMAN 8t. EELD _ H 418 E. CanOn Perdido Street H Santa Barbara. CA 93101 Tel: 805-965-4540 ~ 02-: Fax: 805-965-5009 on. The documents were served by the following means: .—a FE L- (EV MAIL) l sealed the envelope(s). with postage thereon fully prepaid, and on the —- date below. Iam readily familiar with the firm's practice for collection and processing correspondence for mailing. Under that practice, ch ch same day that correspondenceis placed for collection and mailing, it is deposited in the ordinary course of business with a—n a... the U.S. Egtal Service. (BY OVERNIGHT ~ DELIVERY) By placing such sealed envelope. delivery fees paid. in a facility regularly maintained by an overnight delivery service for receipt of such ' -N' M documents. (CCP §1013) [:1 (BY FACSIMILE) By transmitting to a facsimile machine maintained by the recipient N' at the facsim..le machine telephone number as lastjiven by that person. new” (STATE) I declare under penalty of perjury under the laws ofthe ~ State of California N that the above is true and correct. N Executed on Septrnber 2-2,2014, at South San Francisco. Caiii’omia. N N Lukomski ' Natalia N m 259 064 PROOF OF SERVICE